In Karnataka’s Amogasidda Temple dispute, how SC decided who would conduct puja rituals

The Supreme Court last month dismissed a long-running dispute over hereditary pujari rights at the Amogasidda Temple in Karnataka’s Vijayapura district, affirming the findings of the lower courts that the Wadeyar family from Jalageri are the hereditary wahiwatdar (manager or trustee) pujaris entitled to conduct rituals at the temple. A bench of Justices Prashant Kumar Mishra and K Vinod Chandran upheld a 2012 judgment of the Karnataka High Court, recognising the respondent’s right to perform puja at the samadhi temple of Saint Amogasidda at Jalageri village. The dispute between the two families — the Wadeyar family from Jalageri and the Birader Wadeyar family from Arakeri — over the right to conduct and perform rituals has extended for more than a century. We explain. The dispute The case pertained to hereditary pujari rights, a form of traditional temple service where particular families claim the right to perform religious rituals across generations. In temples across India, the right to conduct puja is treated as a hereditary service rather than ownership of the temple itself. Families claiming such rights typically perform daily rituals, conduct ceremonies during festivals, and may receive offerings made by devotees. In this case, the right in question was the right to perform puja of the deity Amogasidda, a saint who passed away 600 years ago. His samadhi was built as a mark of reverence at the temple situated in Mamatti Gudda in Vijayapura district. The respondents (Wadeyar family from Jalageri) claimed that their ancestors had long served as hereditary wahiwatdar pujaris of the Amogasidda temple, meaning they not only performed rituals but also managed the temple’s religious services. This was supported by documentary evidence of revenue records, which showed lands granted historically for services rendered to the temple. Such service grants were common in earlier periods, when rulers or colonial authorities allotted land to temple functionaries in return for maintaining worship. What the appellants claim The appellants, the Birader family from Arakeri, traced their claim to a 1901 civil court decree, which they said recognised their family’s right to perform rituals at the temple. But the Supreme Court noted that later events significantly weakened that claim. One of the most important developments occurred in 1944, when the family’s predecessor filed a civil suit seeking possession of the temple. The court treated this as a striking admission. It said: “A party in settled possession does not sue for possession. The very institution of that suit is a categorical admission by the appellants/defendants’ predecessor that possession of the suit temple was not with them at the relevant point in time.” Although permission was granted in 1946 to withdraw the suit with liberty to institute a fresh one, no such suit was filed. Litigation resurfaced only three decades later. History of litigation The dispute has moved through several stages of litigation. In 1986, the trial court issued a split decision recognising both sides as pujaris. The court attempted to resolve the conflict by allowing the parties to perform rituals in turns. The First Appellate Court later reversed this arrangement and declared the respondent family as the pujaris of the temple. The matter then reached the Karnataka High Court in a second appeal. Initially, the High Court dismissed the suit on jurisdictional grounds, holding that the dispute should be examined under proceedings relating to the registration of public trusts. In 2003, however, the Supreme Court set aside that decision and directed the High Court to decide the case on its merits. After reconsidering the evidence, the High Court again upheld the respondent’s family claim, concluding that the documentary record supported their case. It was this High Court order that was challenged in the Supreme Court. What the top court held The respondents relied heavily on revenue records relating to temple lands. These records reflected the names of the respondents’ ancestors as persons connected with the lands granted for temple service. The appellants’ names did not appear in these entries. Rejecting the appellants’ attempt to question the evidentiary value of these records, the court said that “the names of the appellants/defendants find no mention in these revenue records whatsoever. The appellants/defendants and their predecessors have been litigating over this very temple for over a century. They cannot, in these circumstances, feign ignorance of the revenue records or claim that such entries carry no evidentiary weight against them.” The court noted that such records can indicate longstanding possession, enjoyment of rights, and performance of temple services. Authoring the judgment, Justice Mishra said the respondents’ claim was supported by a consistent body of evidence, including documentary records, witness testimony, and admissions made during the proceedings. The order also noted that the appellants’ reliance on the century-old decree of 1901 could not outweigh later developments, particularly the 1944 suit seeking possession of the temple. Finding no error in the High Court’s appreciation of the evidence, the bench dismissed the appeals.